I am responding to the request in the NOP of EIR for comments on specific
topics that should be addressed in the Infill EIR for the new Greenheart
project at 1300 ECR. Thomas Rogers on July 10, 2014 determined that
infill effects “WOULD be significant.

1. All work should be done per Menlo Park’s Transportation Impact
Analysis, including the requirement as of January 2014 that the VISTRO
analysis, as the successor for the TRAFFIX program should be utilized for
transportation analysis. A near term analysis should be done as well as an
existing and cumulative analysis.

2. Project generated traffic should be distributed to local and
regional destinations based on trip distribution profiles stated by the
City of Menlo’s Circulation System Assessment (CSA) Document. These
distribution profiles only specify the origin/destination of the trips, not
the route used to travel to these origin/destinations. Route specific
assignment of traffic on the local transportation network is required and
should be based upon various alternative access configurations, as well as
local knowledge of the local transportation network and travel patterns.
This was done by W-Trans in its 500 ECR Traffic operational analysis for
Menlo Park. These trip assignment alternatives used should be specified
and explained in a manner to be understandable by the public, including
residents, decision makers, and developers of the Project.

3. Neighborhood cut-through analysis should be assessed for all
roadways between ECR and the Alameda and San Fransquito Creek and
Valparaiso, as well as ECR and Middlefield, Encinal and Willow, and willow
and Marsh road. See geographical gateway discussion for different uses in
Paragraph 5 below. W-Trans in the 500 ECR consistency report of March 7,
2014, p 10 found significant route changes from the Specific plan EIR,
which increased trips on Middle from 87 to 528, AM peak hour from 4 to 63,
and pm peak hour from 9 to 67. These peak hour increases are not only
substantial, but will affect LOS at various intersections. Office space
generated more trips at peak hours than other uses, in addition to
geographic changes.

4. Alternatives should be included for reasonably anticipated changes
in the roadway system or the project. These alternatives should include
the following;

a. Three full lanes on ECR through town as Henry Riggs has recently
published in the Almanac, and which he states was supposed to happen for
Specific Plan infrastructure further states “has begun”. That change in
itself requires additional CEQA work.

b. Other proposed changes to ECR being currently studied by the City’s
El Camino corridor study, including pedestrian and bicycle crossings on
ECR, and access north south on ECR, particularly if Riggs accurately stated
the city is installing three lanes through town in each direction. .

c. Inclusion and non-inclusion of an additional right turn northbound
from ECR to Ravenswood as urged by Council Member Ohtaki.

d. Limitation of office space by the Ballot Initiative to the Menlo
Park ECR DSP. Although Menlo Park spent approximately $150,000 in
anticipation of passage of this initiative, the consultant’s report did not
include any competent Traffic Impact Analysis of office space limitation.

e. The changes to traffic patterns identified in the W-trans reports
regarding traffic related to Stanford’s 500 ECR project including the
changes on Middle and also analysis of Cut through Traffic, as well as
changes in any EIR’s done in Menlo Park in the past two years.

f. Because of the congestion on ECR a vehicular analysis of the
project should be done assuming no ECR access.

5. All 14 residential and non-residential roadway segments and the 27
intersections identified on page 4 of the NOP should be included in the
Transportation Impact Analysis, plus additional roadway segments and
intersections reasonably required because of geographic differences in the
CSA between office space, and other non- residential and residential
space. Pursuant to the CSA 69% of office trips have gateways on I-280, S
101, and SR 84 east, opposed to only 16% retail, which are much more
local. The prior 1300 project was primarily retail, a grocery store, as
approved and studied . To get to the projected gateways, 69% of the office
traffic will have to use other roadways and intersections, which should
also be studied after trip distribution and trip assignments are
determined. Possibilities include :

a. Roadway segments:

i. Ringwood From
Middlefield to Bay

ii. Willow from Laurel to
Middlefield

iii. Willow from
Middlefield to Bay

iv. Marsh from Bay to US 101

v. Santa Cruz from ECR to
Alameda Avy

vi. Avy from Alameda to
Monte Rosa

vii. Monte Rosa from avy to
sand hill

viii. Middle Ave from ECR to
Olive

ix. Olive from middle to Oak

x. Oak from olive to Sand
hill

xi. ECR from Sand Hill to

b. Intersections:

i. Middle and University

ii. University and Roble

iii. University and Menlo

iv. Cambridge and University

v. Middle and Yale

vi. Middle and Princeton

vii. ECR and Sand Hill

viii. Marsh and Bay Road

ix. Marsh and Scott

x. Ringwood and Bay

6. The amount of traffic to be generated by the 1300 ECR project should
be added to the 13, 385 ADT projected by the specific plan area by the
Specific Plan EIR because no traffic was included for this area in those
13, 385 ADT, because the pending project traffic, if at all, was only
included in the 30 year cumulative comparison, not the 13,385 projection.

7. Intersection Queuing should be considered on all ECR Intersections
and all Intersections within 4 km of ECR on streets accessing ECR.

8. New traffic counts should be done on all roadway segments and
intersections to be included in the EIR.

9. The EIR and the Planning commission should both review
determinations of what new development should be considered net new
development under the Specific Plan. As noted in the Wise report Staff
uses inconsistent methods, primarily to maximize the allowance for net new
development, by making improper exclusions. The Specific Plan EIR test was
only exclusion for existing buildings occupied at the time. The prior 1300
Greenheart project was never built or occupied. Also the Marriott net new
development test of comparison of equivalent space with traffic counts was
fictitious.

Don't hesitate to contact me with any questions or comments. Thank You,
George C Fisher